By David Wojick
I submitted the comments presented below on the draft Wyoming State Wildlife Action Plan (SWAP), pointing out several serious errors in their treatment of golden eagles. They do not give the severely threatened eagles anything like the priority that is needed for their protection, especially from being killed by wind turbines.
The comments are in the jargon of the SWAP, so here is a brief introduction. The SWAP homepage is here.
The SWAP is a federal report required for federal funding that is done every ten years. It identifies 308 “Species of Greatest Conservation Need” which are grouped by priority based on a complex ranking system. For each species it also gives a summary of helpful voluntary protective actions that might be taken as well as challenges. Despite the title, it is in no sense a plan, more of a hope list.
Regarding the jargon, NSS is the Native Species Status, which is the basic ranking. Ba and Bb are degrees of risk. In Bb, the population is declining, but the factors causing that decline are not increasing, while in Ba, they are increasing. There are two levels of priority — Tier I is high, and Tier II is lower.
Here are the comments regarding errors in the treatment of golden eagles:
“The Wyoming State Wildlife Action Plan (SWAP) has three primary components — (1) various rankings plus (2) challenges and (3) suggested volunteer actions. Our concern is the golden eagle which is incorrectly characterized in several ways, as briefly explained below.
First, in Table 2 the status should be Ba and NSS2 not Bb and NSS3. The major limiting factor of wind turbines killing eagles is severe and will continue to increase rapidly given present plans. Bb and NSS3 are for cases where the limiting factors are not growing and this is incorrect for the golden eagle.
Second, the priority should be Tier I not Tier II because the golden eagle is on the verge of ESA threatened status and conservation is clearly feasible. A stated goal of then SWAP is “reducing the need for future listings under the Endangered Species Act.” The already modest golden eagle population has reportedly dropped by 30% in the last two decades as the wind turbines have proliferated. The eagle is clearly threatened and preventing further decrease should be a very high priority, not Tier II.
See my prior article for more details.
Third, the recommended volunteer actions fail to include the obvious action of reducing the number of new wind turbines erected in Wyoming. Most of the developers have numerous projects outside of Wyoming and they could easily voluntarily forego building here, in order to save the eagles. This volunteer action should be added to the list.
Fourth, the recommendation that roadkill be collected in order to reduce vehicular collision may be a bad plan. The most recent FWS estimate of golden eagle death rates places starvation at the top of the list, far above collisions. Eagles are being struck because they are feeding on the roadkill. It is entirely possible that collecting roadkill would cause more eagle deaths from starvation than it prevents from collision. This volunteer action should be removed from the list until the issue is settled scientifically.
Fifth, the challenges say there is both a lack of information and a lack of funding for protecting the golden eagle. The eagle and these sad lacks should be at least mentioned, or better to be discussed, in Chapter 3 as the golden eagle is clearly a species of great conservation need.
In summary the golden eagle should have a much high priority than the present draft provides. I will be happy to provide additional information on this issue.
Respectfully submitted,
David Wojick, Ph.D.
CFACT”
End of Comments
Given the widespread and growing concern over Wyoming golden eagles being killed in increasing numbers by wind turbines, it is both astounding and disturbing that the SWAP gives them such a low priority. See for example this.
The draft SWAP is fundamentally wrong and must be corrected. Wyoming must act to protect the golden eagles.
Good comment. Fight on.
Thanks. If they do not change the priorities I will contest the federal grant. That should get their attention. I had hoped for better out of the WY govt.
I’ve said it before. What needs to be legislated is these companies need to put a screen around these spinning blades. The standing fans in our homes have a grill around the blades to protect us and our kids and pets. How did these companies get away from not supplying a safety grill?
These spinning blades have already killed how many?
It’s time to turn them off, and not let the blades turn again until that situation is corrected.
One differently colored blade has been shown to mostly solve the problem. A screen would be impractical.
Then why don’t the Feds require it as a mitigation when they isdue eagle kill permits to wind turbines? I suspect it is just a conjecture at this point with one positive test result.
Legal hesitancy, and anticipation of objections by turbine operators to costs for currently installed. Make a significant sample size paint, and all US operators cover the costs of assessing follow up death results. Operators might whine, but the current evidence points to the efficacy of this solution.
why try to fix a fake solution to a non-existent problem, CO2 does not control the climate of the planet.
The article is about eagles. The denier problem is that, even disregarding ACC, fossil fuels are losing in the marketplace to wind/solar. Hence the pearl clutching about glitches orders of magnitude smaller than those fossil fuels face. Depletion, shirked asset retirement obligations, security costs, just to start. All costs communized on those who can least afford them.
Really? Global Energy Mix figures for June show fossil fuels contributing 82.6%, while solar only contributed 4.8% and wind 3.3%. Exactly how are fossil fuels losing in the marketplace?
W and S are GAINING power/market share. Fossil fuels, the other way. We’re on the down side of Hubberts curve, even with the big players hysterically blinded to ACC. UNLESS we MacGyver SMR’S within a fraction of a blink of an eye w.r.t. recorded human history, we’re due for some serious teeth gnashing. But what do you care, with your 1 gen mind set?
The recently published ‘Energy Institute 2026 Statistical Review of World Energy’ says in 2025
“Fossil Fuels continued to expand in absolute terms and retained their dominant position accounting for 86% of Total Energy Supply”
And, of course, the operators will just request an adjustment to their subsidies to pay for the painting and the extra reporting.
Happy to drop all of the relatively tiny renewable start up helps if the fossil fuelers do the same. Security costs – Iran is just the latest. Catch up on insuring/lockboxing 13 $ figures worth of shirked/to be shirked asset retirement obligations. Real enforcement of API environmental, health, safety, responsible care, best practices, world wide. World wide crackdown on kleptocratic theft of oil/gas revenues (most new exploration is in lands most susceptible). Notice NO mention of ACC. Just source v source, $ v $. Per Al Bundy, let’s rock…
Fossils do not burn. Fossils are not fuels.
Iran is not a cost of importing fuels. Iran is a half-century long problem originating in the Islamic awakening. A nation with vast energy reserves taken over by fanatics who have a burning “death to America” and “death to the little Satan” fixation.
They would gladly start an atomic war if they thought it would hasten the return of the Twelfth Imam. They do.
Oh, and the shirked asset retirement issues of renewables are just a decade or two away.
A stupid solution, it will unbalance the rotor.
Although if the rotor fails and stops spinning, the result is a win for eagles.
Balancing rotating mass is a centuries old human skill.
How much will this add to the cost of your “free” wind energy?
Not nearly enough to make it lose to FF’s $ v $. And what do you think tire techs are doing with those little lead weights? I guess I actually had some benefit to my mom’s death as an infink and being raised by dad. An understanding of many things mechanical, for example.
Maybe someone should have exposed you to economics.
Recent research in Finland showed that warning colours of yellow red and black were more frightening to birds than patterns already used such as a single black blade and red stripes.
Most turbines of course use only white blades with no attempt at warning the birds.
Funny that. Look at the propellers on WWII fighters. Seems familiar.
How are the bats going to see a different colored blade?
Golden Eagles are only one of the critters the Cuisinarts kill.
Yes a screen would be impractical, but I have heard variations of the “differently colored blade” solution for many years now and it doesn’t gain traction. I don’t think there is much in the way of evidence that such actually works, and the FAA I’m pretty sure has jurisdiction over it. As long as they think it may confuse general aviation they shouldn’t allow it.
People of America, the emblem of your proud nation and civilisation is being massacred by a dangerous modern technology.
The Eagle is being vanquished, what are you going to do to avoid your humiliation?
You are a laughing stock amongst the nations.
Windmills are not just a dangerous modern tech, they are a dangerous medieval tech upgraded to a whole new level of bad news. As for the other nations-they are so fked by their own stupidity that what they think is totally irrelevant. Can we interest you in some greenie blobettes-we do seem to have too many of them.
Wrong eagle, me thinks.
I did wonder about that. What protects the right one?
The Eagle protection act covers both Bald and Goldens. The big problem is they are issuing kill permits based on a false theory of the kills being offset by electrocution reduction.
See my http://www.cfact.org/wp-content/uploads/2025/06/Wojick-Eagle-Kill-Report-Final.pdf
someone missed the sarcasm
Wind and solar can’t support the grid even working together. There is no way either could stand on its own. Even working together they both require huge amounts of support from various forms of government. Even with all this support they require mandates forcing them to be included in the mix. Even with all this help they are very expensive hard to recycle and dispose of. Why on earth are we still messing around with them? The fact that they are taking up valuable real estate and killing birds, bats and such is a no brainer, get rid of them now.
You left out excessive land use and your recycling and disposal omitted environmental damage to to toxic martials.
Not negative criticism, merely augmentations.
It has been my contention for quite a few years that Greeners only care about renewables from wind and solar .. they are not true environmentalists Wind‑turbine mortality is systematically underreported — scavengers remove carcasses within hours, injured eagles die far from turbines, and surveys are infrequent — but the deeper problem is that the regulatory system has effectively legalized Golden Eagle killing. The U.S. Fish & Wildlife Service’s own data show that wind facilities are granted “incidental take permits” allowing authorized eagle deaths (USFWS, Eagle Incidental Take Program, 2016), and peer‑reviewed studies confirm that actual mortality exceeds reported counts due to carcass removal and limited search radii (Smallwood, 2020; Loss et al., 2013). When mortality exceeds permitted limits, operators can request higher allowances rather than face penalties. In any other context, killing a protected raptor triggers prosecution; in the wind‑energy context, it triggers paperwork — and the Green movement refuses to acknowledge this because it contradicts the narrative that wind is “wildlife‑friendly.”
I find these facts to be truly heart rendering: Note that the U.S. Fish & Wildlife Service we rely on for wildlife protection formally created the Eagle Incidental Take Permit system in 2016, which allows wind operators to kill a set number of Golden Eagles per year (USFWS, Eagle Incidental Take Program, 2016). That’s not environmental protection — that’s regulatory normalization of mortality.
Even worse the 2024 law eliminated the allowable take numbers.they wanted to make the permitting more wind friendly because a lot of wind facilities simply ignored the permitting, hoping they did not kill an eagle. Even then the fine is much less than the cost of having a permit.
The permit should be a condition of operation.
See my https://www.cfact.org/2026/06/20/golden-eagles-need-new-law-to-protect-them-from-wind-turbines/
Sounds like they’re saying, “We’re succeeding in not killing Eagles on power lines. So it’s OK to kill them with something else!”
The wind projects pay to have the power lines made safer. But the numbers are ridiculous. They assume 350 fixes saves an eagle but it is more like 67,000. This is explained in my report which the Feds ignore.
What is needed is a windmill design update that allows the eagles to kill the windmills.
Why? An accurate count of collisions and maybe a few less birds killed.
In WW2, the US experimented with a “bat bomb” to be used on Japan.
A small incendiary bomb was strapped onto the bats and they were to be dropped in specially designed bat-coop bombs over Tokyo. The idea being they would hide in the wooden buildings until the bomb’s timers went off.
(The program was cancelled after a test drop destroyed the base’s building.)
Maybe strap some C4 to a few eagles and bats with an impact fuse? 😎
I remember that bat experiment. Funny.
Not sure about the C4 idea, but ideas are needed.
Carry on.
I have hunted Wyoming and driven through it a couple times and the windmills were so pervasive it made me nauseous.
I think boxes of Remington ammo in .243 are about $20 apiece. At one round per windmill we are looking at what, $1,000?
And there are permits enough in the pipeline to nearly double them. Then there are the designs of nearby westerns states to develop Wyoming and Montana wind for import to themselves — i.e. basically colonizing WY and MT for wind energy, which calls for about another doubling again.
Along with the expanded transmission lines and substations involved it will be a disaster.
David,
My view is that reckless development in Wyoming is about a two decades old problem and will require a multi front campaign if it can be corrected at all. It is the result of ownership (many big land owners live elsewhere) in the state, the way government works, and too many people thinking they see “$ $ $!”. That was the point of my personal critique.
First, I would hope that your comments cause some change, and if they don’t, then I hope your resulting complaint does. However, I am doubtful because people at the Wyoming Game and Fish (WGFD) have told me they are pressed from above to “not push back on wind” as they put it. The wildlife biologists are conflicted anyway because they deeply dislike fossil fuels and view climate change as an existential threat. So, WGFD is an unlikely ally.
Asking questions about impact fees I have never seen do anything productive. The fact is that impact fees are distributed from State coffers prior to any money coming from developers and serve as an incentive to ignore critics and grant permits anyway. These impact fees are often wasted.
As I stated to you and others, one really has to get the legislature involved, and I’m focusing on that effort. First, State Senator Cale Case has suggested a severance tax on renewable projects that impact viewsheds, tourism, and wildlife. Second, I’m more focussed right now on addressing the messy approach in this state to nuisances — noise and flicker. A uniform approach to this issue across the state would perhaps do a lot to save homeowners and users of public property from having to put up with value destroying nuisances that are treated cavalierly by the developers.
How about a public campaign of countering the developers statements such as “Wyoming needs this energy”? Or their assurances that a Oklahoma style land rush to wind plants, solar, and batteries will not affect safety, utility rates, or burden the counties down the road with decommissioning. Put out some ads to users of Black Hills Power or the WAPA power lines to the effect of “Are renewables lowering your utility bills? Or just pushing wildlife to the brink?”
Stuff like this.